Declaration of Jane Doe — America's Frontline Doctors, et al. v. Xavier Becerra, et al.

What This Document Is

This two-page declaration, filed as Exhibit D to the July 19, 2021 Motion for Preliminary Injunction (Doc. 15), is executed under 28 U.S.C. § 1746 by a pseudonymous declarant identified only as "Jane Doe," describing herself as a healthcare data analytics professional with CMS data access, submitted in support of revoking the COVID-19 vaccine EUAs.

Factual Summary

The declarant states she is a computer programmer with 25 years' experience building healthcare fraud-detection algorithms, with access to CMS Medicare/Medicaid claims data. She states that, as of July 9, 2021, VAERS reported 9,048 deaths following COVID-19 vaccination, and that she independently collated that VAERS data herself. She states her professional estimate, based on cross-referencing CMS claims data for deaths occurring within three days of vaccination, is that VAERS undercounts actual vaccine-associated deaths by "a conservative factor of at least 5," yielding an estimated true figure of "at least 45,000." She contrasts this with 53 deaths that led to the 1976 swine flu vaccine's withdrawal from the market. The declaration is signed "Jane Doe" and dated July 13, 2021, executed under penalty of perjury.

Key Facts

Filed July 19, 2021 as Exhibit D to Doc. 15, Case No. 2:21-cv-00702-CLM (N.D. Ala.).
Declarant is pseudonymous ("Jane Doe"), stating she fears for her personal safety and her family's.
States VAERS reported 9,048 deaths as of July 9, 2021.
Estimates true vaccine-associated deaths at "at least 45,000" based on a claimed 5x CMS-derived undercount factor.
Cites the 1976 swine flu vaccine's 53-death withdrawal threshold as a comparison point.

Source Caveats

The declarant's identity is not disclosed (pseudonymous "Jane Doe"); her stated credentials and data access are unverified from this document alone.
VAERS is a passive-reporting system that accepts unverified reports without confirming causation; the declarant's "at least 45,000" figure is her own extrapolation from CMS claims data, not a CDC- or CMS-published causation finding, and is not adjudicated by any court.

Date: 2021-07-19

Full text

DECLARATION OF Jane Doe

Pursuant to 28 U.S.C. § 1746, Jane Doe, hereby declares:
I am fully competent to make this declaration and I have personal

knowledge of the facts stated in this declaration.

This declaration is submitted in support of legal actions to revoke the
emergency use authorization for COVID-19 injections and in support of a
preliminary injunction to immediately block the emergency use
authorization for COVID-19 injections.
I am a computer programmer with subject matter expertise in the
healthcare data analytics field, an honor that allows me access to Medicare
and Medicaid data maintained by the Centers for Medicare and Medicaid
Services (CMS).  I earned a B.S. degree in Mathematics and have, over the
last 25 years, developed over 100 distinct healthcare fraud detection
algorithms, both in the public and private sector.  It has been my mission to
protect federal tax dollars by preventing and detecting healthcare fraud, a
process which leads to both recovery of overpayments and law enforcement
leads.  A large part of what I do is focused on the quality of care for the
beneficiary; for example, I identify providers who prescribe an egregious
amount of opioids to patients with a history of overdosing.  Instead of titrating
the patient off of opioids, they prescribe more, oftentimes leading to patient
death.  When the COVID-19 vaccine clearly became associated with patient
Ex. D
FILED
 2021 Jul-19  PM 01:01
U.S. DISTRICT COURT
N.D. OF ALABAMA
Case 2:21-cv-00702-CLM   Document 15-4   Filed 07/19/21   Page 1 of 2

death and harm, I was naturally inclined to investigate the matter.
It is my professional estimate that VAERS (the Vaccine Adverse Event
Reporting System) database, while extremely useful, is under-reported
by a conservative factor of at least 5.  On July 9, 2021, there were
9,048 deaths reported in VAERS.  I verified these numbers by
collating all of the data from VAERS myself, not relying on a third
party to report them.  In tandem, I queried data from CMS medical
claims with regard to vaccines and patient deaths, and have assessed
that the deaths occurring within 3 days of vaccination are higher than
those reported in VAERS by a factor of at least 5.  This would indicate
the true number of vaccine-related deaths was at least 45,000.  Put in
perspective, the swine flu vaccine was taken off the market which only
resulted in 53 deaths.
I declare under penalty of perjury under the laws of the United States
of America that the foregoing is true and correct.
Executed on July 13, 2021.

/s Jane Doe

Jane Doe
Ex. D
Case 2:21-cv-00702-CLM   Document 15-4   Filed 07/19/21   Page 2 of 2

File and source

File: gov.uscourts.alnd.177186.15.4.pdf
Size: 564,690 bytes
SHA-256: 76a90cf2a058fe0e47c0449a3a2d1907fbaa851239c4230e021b0b494eee0e50
Our copy: gov.uscourts.alnd.177186.15.4.pdf
Original: archive.org